----- Forwarded by Melanie King/RTP/USEPA/US on 11/01/2010 04:14 PM

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 |"Ronald A Kunkel" <rkunkel@woodburyrec.com> 

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| To: |

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 |<wayland.robert@epa.gov>, Melanie King/RTP/USEPA/US@EPA, 

<Kevin.bromberg@sba.gov>, <bill.wemhoff@nreca.coop> 

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| Cc: |

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 |"'Ronald A Kunkel'" <rkunkel@woodburyrec.com>, "'Chuck Soderberg'" 

<csoderberg@nipco.coop>, "'Kent Pauling'" <kpauling@nipco.coop> |

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| Date: |

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 |11/01/2010 04:08 PM 

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| Subject: |

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 |Support for NRECA's RICE Petition for Reconsideration 

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Ladies/Gentlemen EPA/SBA:

We are sending email copies of Woodbury REC support for NRECA;s RICE Petition 

for Reconsideration to Robert Wayland at EPA ( wayland.robert@epa.gov ), 

Melanie King at EPA ( king.melanie@epa.gov ), and Kevin Bromberg at the Small 

Business Administration ( Kevin.bromberg@sba.gov ). Bill Wemhoff 

bill.wemhoff@nreca.coop is also receiving a copy.

NRECA’s Petition for Reconsideration was filed Wednesday October 20th and 

argues for rule revisions that would eliminate the peak shaving and demand 

reduction restrictions EPA has placed on the units in the 100 hours of nonemergency operation. It also argues for a petition provision whereby 

owners/operators with special circumstances requiring additional operating 

hours could petition the Agency for those additional hours without being 

required to add emission controls.

Woodbury REC supports this Petition for Reconsideration in the attachment 

“2010 Woodbury REC - - EPA RICE letter.docx”.

.

Sincerely,

Ronald A. Kunkel, CEcD, EDFP

CEO & General Manager

Woodbury County Rural Electric Association (Woodbury REC) PO Box 566 Moville, 

Iowa 51039

Tele: 712-873-3125(See attached file: 2010 Woodbury REC - - EPA RICE

letter.docx)
November 1, 2010 

The Honorable Lisa Jackson 

Administrator 

United States Environmental Protection Agency 

Ariel Rios Building (Mail Code 1101) 

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460 

Re: Petition for Reconsideration of Portions of the Final Rule: National Emission 

Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 

Dear Administrator Jackson: 

I am writing in support of the National Rural Electric Cooperative Association’s (NRECA) 

October 19, 2020, Petition for Reconsideration of portions of the Final National Emission 

Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 

promulgated on August 20, 2010, (75 Fed. Reg. 51,570). 

Woodbury Rural Electric Cooperative Association (Woodbury REC) is headquartered in 

Moville, Iowa 51039. Woodbury REC is one of the 7 Member Cooperatives of Northwest Iowa 

Power Cooperative (NIPCO). NIPCO is a Generation and Transmission Cooperative 

headquartered in Le Mars, Iowa. Woodbury REC provides power and various services to its 

3,300 member/consumer/owners in western Iowa that covers 2,000 square miles. Woodbury 

REC with NIPCO have also had a very successful active load management system in place since 

1983. Over 30% of the 3,300 consumer/member/owners participate in this demand-side 

management program. 

If left in place, the EPA National Emission Standards for Hazardous Air Pollutants for 

Reciprocating Internal Combustion Engines (RICE NESHAP) rule will severely restrict and limit 

our ability to maximize efficient operations of our electric systems. This ruling will also have 

negative power supply implications as we will be unable to operate our system as efficiently as 

we current do. This will increase our costs and ultimately our rates to the 

consumer/member/owners. Along with other parts of our country, western Iowa struggles to 

meet the challenges of the downturn in the country’s economy. Unemployment is high, people 

are struggling to make ends meet and businesses are fighting to stay open. This is certainly not 

the time to place additional burdens on them. 

Woodbury REC, as a Distribution Cooperative, has no major electric generation facilities of our 

own, but we are concerned primarily with distributing electric power to our retail consumers. 

Woodbury REC simply does not have the resources or a practical reason to keep track of and 

review the many EPA rulemaking activities under the Clean Air Act to see if one of these 

rulemakings may have an impact on our operation of delivering electrical power. Without an 
outreach from EPA, which was absent in these rulemakings, Woodbury REC could not anticipate 

that the proposed rule for emergency generators would undermine and destroy our very practical 

and highly successful peak shaving programs. 

The bulk of the small emergency generating units, the subject matter of this petition, are owned 

by the rural consumer/member/owners of the electric cooperatives and not by Woodbury REC. 

These small emergency generating units are utilized in an efficient and productive manner for the 

benefit of our rural consumer/member/owners. It is hard to understand and explain that the 

efficiency benefits derived from the use of these resources would be wiped out by a Federal 

Government that professes goals of increased energy efficiency and resource conservation. 

NRECA’s petition addresses restrictions contained in the final rule that prohibit the use of small 

emergency generating units for peak shaving programs and limits demand reduction service 

beginning in 2013 without the addition of expensive emission reduction technology on units 

larger than a specified size. 

To help operate our electric system more efficiently and maximize not only our power supply, but 

our distribution system, our load management system includes a peak shaving program that uses 

the engines you will be regulating and restricting the use thereof. Without the use of these back-up 

generators, the cost of power will increase as there will be no other cost-effective option to reduce 

our demand during peak usage times. The added capital expenditures placed on our 

consumer/member/owners to make the required upgrades under this regulatory mandate places a 

very significant financial burden on them. This may force us to cease future peak shaving demand 

side management program as they will no longer be cost effective for us or the consumer-owner to 

consider. 

We support the recommendation contained in NRECA’s petition regarding removal of the 

restrictions on the use of these engines for peak shaving and demand reduction purposes in the 

100 hours of non-emergency operations allowed in the rule. The use of these engines up to 100 

hours for non-emergency operation per year, as already allowed in the final rule, would not cause 

any additional emissions and therefore, no additional health risk or environmental harm above 

that already contemplated in the rule. 

In conclusion, Woodbury REC, its consumer/member/owners support protecting public health 

and the environment. However, in this case the restrictions are unnecessary, too severe, will 

cause a significant detriment to our consumer/member/owners, and will not result in any 

meaningful environmental benefit. We urge the agency to reconsider these restrictions on peak 

shaving and demand reduction contained in the final rules and amend the rules avoid diminishing 

the value of these programs and increase the cost of power to our consumer/member/owners. 

If you have any questions or need additional information, please contact me at 712-873-3125. 

Thank you Administrator Jackson for your consideration of our request. On behalf of our 3,300 

consumer/owners/members, we express our desire you will respond favorably on this critically 

important issue. 

Sincerely, 

Ronald A. Kunkel 

CEO & General Manager 
e-mail cc: 

Robert Wayland 

 Melanie King 

 Kevin Bromberg, SBA